Modern Slavery Act Statement 2019

This is Utmost Limited’s statement on its approach to modern slavery following the introduction of the UK Modern Slavery Act 2015 (the “Act”).

This statement sets out the steps taken or actions underway by Utmost Limited during the financial year ended 31 December 2019 to assist in the detection and prevention of modern slavery across its business operations and supply chains.

Who are we?

Utmost Limited is based on the Isle of Man and is a member of the Utmost Isle of Man Group (the “IOM Group”), which has provided life assurance and capital redemption bonds to high net worth clients predominantly located in the United Kingdom through fully regulated partners and intermediaries for the past 26 years. It has approximately £10bn of assets under administration as at 31 December 2019 and strives to offer its clients outstanding levels of service and innovative products.

Our Internal Policies

Our internal policies in respect of measures which could assist in preventing modern slavery from taking place in our business dealings are kept under review on an annual basis.

We follow the principles of good corporate governance and Enterprise Risk Management and do not tolerate any malpractice, whether committed by senior managers, staff, suppliers or contractors acting on our behalf (“our Governance Framework”).

A Code of Conduct (“Code”) is included in our Governance Framework and applies to all directors, officers and employees and requires that they adhere to the Principles of Conduct and Ethics (the “Principles”). The Principles state that staff must act with integrity, objectivity, confidentiality and in a professional manner. Staff are encouraged to report any practices or actions where they believe these to be inappropriate or inconsistent with the Code or that may compromise the ethical standards or integrity of the organisation.

The procedure for reporting inappropriate, unethical or inconsistent practices with the Code is set out in our Whistleblowing Policy. This policy provides for a member of staff to report any improper conduct or unethical behaviour in the first instance to their manager, senior manager or the Chief Executive Officer directly if they wish.

Where they feel that they cannot raise a concern with these individuals, they may make contact on a confidential basis with the Chairman of the Audit Committee, after which their report will be investigated and considered by all of the Non-Executive Directors. At all times during any investigation the Whistleblower’s identity will be kept confidential. Staff members are reminded of their right to raise concerns under the Whistleblowing Policy, and to consult with associated guidance, by the Chairman of the Audit Committee annually.

Our Suppliers

Utmost Limited accepts a range of goods and services from suppliers located across the globe, although the majority of suppliers have their operations locally in the Isle of Man or the United Kingdom. Goods and services utilised by us consist of catering, cleaning, office furniture and stationery, Information Technology, property maintenance and utilities.

The following supplier measures are in place across the IoM Group:

Supplier Risk Assessment

The Group Business Risk Department assesses our suppliers annually using a risk-based approach to identify those which are deemed to be higher risk. This assessment is based on their area of geographical operation, the type of industry in which they operate and their publicly disclosed policies on slavery and human rights.

Where a supplier is identified as medium or high risk, they are contacted to inform them of what is expected from them to comply with the terms of the Act. If the supplier indicates that they have no policy or similar in place, we will, where practicable, identify an alternative supplier.

Procurement Policy

The Utmost Isle of Man Group Expense, Capital and Procurement Policy requires that when a supplier is selected, a principle-based approach is adopted under the selection process. One of the principles requires that the Act be observed as part of this process.

Contractual Terms

Where a supplier contract is to be entered into or renewed, we will negotiate terms to include standard contractual obligations seeking to ensure that the supplier operates in compliance with the Act.

Approved by the Board of Directors of Utmost Limited

31 March 2020